Kings Roofing NWFL, LLC v. Fusion Works Construction, LLC
The Sixth DCA dismissed this construction subcontractor appeal by stipulation but retained jurisdiction to pursue potential sanctions against the appellant's attorney, who submitted an Initial Brief containing citations to fabricated or non-existent cases — the hallmark of generative AI hallucination. The court is the second 6th DCA AI-hallucination sanctions case in 2026 (after Rodriguez, April 2026), and directly contributed to the Florida Supreme Court's adoption of new Rule 2.515(d)(2) (SC2026-0673, May 28, 2026).
Key facts
- Kings Roofing NWFL, LLC appealed a Lee County Court judgment in a construction subcontractor dispute against Fusion Works Construction, LLC; the appeal was filed by attorney Steven R. McCommon of S.R. McCommon Law PLLC.
- McCommon's Initial Brief submitted to the Sixth DCA contained citations to several cases, some of which appeared to be fabricated — consistent with the hallucination pattern produced by generative AI tools used without adequate verification.
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Holdings
- Appeal dismissed pursuant to parties' Joint Stipulation for Dismissal (Fla. R. App. P. 9.350(c)).
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Why it matters
This is one of the immediately proximate causes of the Florida Supreme Court's adoption of amended Rule 2.515(d)(2) (SC2026-0673, effective June 15, 2026). The 6DCA has now twice in 2026 confronted AI-hallucinated… — full analysis with a trial
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